The defendant is charged [in count __]
with criminal simulation. The statute defining this offense reads in pertinent
part as follows:

a person is guilty of criminal
simulation when with knowledge of its true character and with intent to defraud,
(he/she) issues or possesses an object that has been made or altered in such
manner that it appears to have an antiquity, rarity, source or authorship that
it does not in fact possess.

For you to find the defendant guilty
of this charge, the state must prove the following elements beyond a reasonable
doubt:

Element 1 - Issued or possessed
a falsified objectThe first element is that the
defendant issued or possessed an object that had been made or altered in such
manner that it appeared to have an antiquity, rarity, source or authorship that
it did not in fact possess. Simulation is the assumption of a false
appearance. Criminal simulation is a feigned or fictitious transaction to
effect a fraud. <Insert as appropriate:>

"Possession" means
either actual possession or constructive possession. Actual possession means
actual physical possession, such as having the object on one's person.
Constructive possession means having the object in a place under one's dominion
and control. <See
Possession, Instruction 2.11-1.>

Element 2 - KnowledgeThe second element is that the
defendant knew the true character of the object. A person acts "knowingly"
with respect to conduct or circumstances when (he/she) is aware that (his/her)
conduct is of such nature or that such circumstances exist. <See
Knowledge, Instruction 2.3-3.>

Element 3 - Intent to defraud
The third element is that the
defendant specifically intended to defraud another person. <See
Intent to Defraud, Instruction 2.3-6.>

Conclusion

In summary, the state must prove
beyond a reasonable doubt that 1) the defendant (issued / possessed) <insert
type of object and describe how it had been falsified>, 2) (he/she) knew the
true character of the object, and 3) (he/she) intended to (deceive / defraud /
injure) another person.

If you unanimously find that the state
has proved beyond a reasonable doubt each of the elements of the crime of
criminal simulation, then you shall find the defendant guilty. On the other
hand, if you unanimously find that the state has failed to prove beyond a
reasonable doubt any of the elements, you shall then find the defendant not
guilty.